The European Accessibility Act (EAA) requires organizations to maintain specific documentation proving their products and services meet accessibility standards. This documentation serves two purposes: it demonstrates conformance with EN 301 549, and it provides regulators with evidence during market surveillance.
| Requirement | What It Means |
|---|---|
| Accessibility Statement | A public declaration describing how the product or service meets applicable accessibility requirements under EN 301 549 |
| Technical Documentation | Records showing which accessibility criteria were evaluated, the methods used, and the results of each evaluation |
| Conformance Evidence | Audit reports, scan records, and remediation logs that demonstrate ongoing conformance activity |
| Retention Period | Documentation must be retained for five years after a product or service is placed on the market |
What the Accessibility Statement Must Include
The EAA requires an accessibility statement that describes how a product or service conforms to the applicable accessibility requirements. This is not the same as a brief policy page.
An adequate statement identifies the specific standard referenced (EN 301 549), describes the scope of conformance, lists any known limitations, and provides contact information for accessibility-related inquiries. Organizations selling into multiple EU member states should confirm whether individual countries impose additional formatting or content rules on these statements.
Technical Documentation and Conformance Records
Beyond the public statement, the EAA expects organizations to maintain internal technical documentation. This includes records of accessibility evaluations conducted against EN 301 549, including the specific criteria assessed and the outcomes.
An accessibility audit report is the strongest form of this evidence. Audit reports typically document each criterion evaluated, whether the product conformed, and what remediation was recommended for identified issues. Automated scans supplement this record but are not sufficient on their own, since scans only flag approximately 25% of issues.
Remediation records matter here too. Regulators want evidence not only that issues were identified but that they were addressed. A compliance management platform can centralize this information by tracking each issue from identification through remediation, creating a documented trail.
How Long Documentation Must Be Kept
The EAA specifies a five-year retention period for technical documentation. This clock starts from when the product or service is placed on the EU market. For digital products that are continuously updated, the practical implication is that documentation should be treated as a living record rather than a one-time deliverable.
Platforms designed for accessibility documentation management make this retention requirement easier to meet by storing evaluation history, remediation records, and conformance evidence in a single location with version tracking.
What Regulators Look For During Market Surveillance
EU member states will conduct market surveillance to verify EAA conformance. When a product or service is selected for review, the organization must be able to produce its documentation promptly.
Regulators look for three things: that an evaluation was conducted against the correct standard, that identified issues were remediated, and that the organization has a process for maintaining conformance over time. Documentation gaps in any of these areas create risk.
Connecting EAA Documentation to Ongoing Monitoring
A single audit produces a snapshot of conformance at one point in time. The EAA’s documentation requirements imply something more continuous. As digital products change through updates and new features, the conformance record needs to reflect those changes.
Scheduled accessibility scans create a recurring evidence trail that supplements periodic audits. Combined with a platform that logs remediation activity, this creates the type of continuous documentation record that satisfies the EAA’s intent.
Organizations entering the EU market with digital products or services should treat EAA documentation as an operational process, not a one-time compliance exercise.